Hon. Chris Ballard…

Hon. Chris Ballard
Minister of Environment and Climate Change
Ferguson Block 11th Flr, 77 Wellesley St. W.
Toronto ON M7A 2T5

Re: Regulatory amendments related to air emissions of sulphur dioxide and other items

Dear Minister Ballard,

It was a pleasure seeing you at AMO and thank you for taking the time to meet with me. During that time, we did discuss the concerns Greater Sudbury had in relation to the impact your air emissions regulations would have on our two smelters, and on any future plant or smelter opportunities.

We appreciate the opportunity to comment on EBR#013-0903, the regulatory updates related to air emissions of sulfur dioxide, and would ask that you keep the requirements unchanged in Northern Ontario.

As discussed previously, for more than 100 years, Greater Sudbury’s economy has been rooted in the mining sector. Our community is home to the largest integrated mining complex in the world, consisting of eight operating mines, two mills, two smelters and a nickel refinery. More than three trillion dollars of minerals have been extracted, and have contributed significantly to our local, provincial, and national economy.

With over 100 years of experience in mining, we as a community are committed to mining in a sustainable way and in fact have been recognized by the United Nation for our work in environmental rehabilitation through partnerships built with the various levels of government, the local mining companies, and Laurentian University.

Both Vale and Glencore continue to demonstrate their commitment to improve air quality in our region. Despite an unprecedented downturn in the nickel market, both companies have made significant investments recently totaling approximately $1.5 billion in relation to emission reductions. Vale’s Clean AER Project alone will result in an 85% reduction in sulfur dioxide emissions from current levels and will actually make what is a major landmark in Sudbury, the Superstack, obsolete. The technologies currently being used in Sudbury operations are state of the art.

As we’ve discussed previously, the new proposed sulfur dioxide air standard for Ontario cannot be met at both Vale and Glencore even though significant investments in emission reduction technology have been made. While we share many of the same interests that your government is looking to address, we are concerned about the impact this will have to our local industry and economy, as well as the provincial industry and economy.

In speaking with both Vale and Glencore, they have raised numerous concerns related to the proposed changes including the following:

•Both Vale and Glencore have done their part to reduce emissions. They are in the process of a final combined spend of $1.5B in emissions reduction. Both companies have demonstrated their commitment to improve air quality, with continuous improvement over the years.

•The health of Vale and Glencore’s businesses in Sudbury is dependent on this decision. With expectations continually changing, and with the current continued downturn, it is difficult to forecast and business decisions are being impacted.

•The new standard the Ministry is proposing is unprecedented, even on a measured basis and a site specific standard is not the answer.

•Based on the Ministry‘s monitoring station, on an actual measured basis the companies are below 40 ppb 99% of the time. As Sudbury is spread out, with two large smelters, it is very different from Sarnia. Our communities have very different airsheds and thus a solution for Southern Ontario should look different than one for Northern Ontario.

I know that the Government wants to support mining in Northern Ontario, and this would be a good way to continue to demonstrate this support.

At a time when significant investments are needed to develop new mines to ensure the sustainability of mining operations in our region. As existing mines are nearing end of life, the proposed regulatory amendments mean that both companies are faced with even more investments to be made in emission reductions, all while continuing to operate in a downturn.

These proposed changes will have a negative impact on the mining industry and our local and regional economy.

Considering the concerns and repercussions of the proposed changes, I again ask that the current standards for Northern Ontario remain in place, and unchanged.

Should you have any further questions or concerns please feel free to contact my office.

Sincerely,

Brian Bigger
Mayor

[Original Comment ID: 211508]